Who Needs to Submit Data?
Submittal requirements for the SRP’s electronic data deliverables are included in the Administrative Requirements for the Remediation of Contaminated Sites (ARRCS Rule), (N.J.A.C. 7:26C-1.6) and the Technical Requirements for Site Remediation (Tech Rule), (N.J.A.C. 7:26E–1.6). The regulations require that sample location information and result information from the analysis of the samples, be provided to SRP in an electronic format. In this way, your data can be entered into our data management system, and be made accessible for internal and external data sharing.
The ARRC Rule simply states, in sub-chapter 1.6, that the submittal of “laboratory data deliverables” are required in an electronic format. The Tech Rule, also in sub-chapter 1.6, goes into more detail and lists some of the required fields, timeframes, additions and exemptions.
There are scenarios where some persons are exempt from the EDD process. These exemptions are summarized below. However, review of the actual ARRCS Rule and Tech Rule sub-chapters, is essential. The person(s) remediating a site is exempt from EDD requirements if:
- A final remediation document for unrestricted use is filed within one year of the earliest applicable trigger (see N.J.A.C. 7:26E-1.6(a)5);
- The person(s) is remediating a sanitary landfill which is not slated for redevelopment that includes structures intended for human occupancy (see N.J.A.C. 7:26C-1.4(c)2);
- The person(s) is remediating a sanitary landfill that is not funded with Hazardous Discharge Site Remediation Fund (HDSRF) funds (see N.J.A.C. 7:26C-1.4(c)2);
- The person(s) is remediating a discharge pursuant to a New Jersey Pollutant Discharge Elimination System Underground Injection Control permit issued pursuant to N.J.A.C. 7:14A (see N.J.A.C. 7:26C-1.4(c)3); or
- The person(s) is remediating a discharge from an unregulated heating oil tank (see N.J.A.C. 7:26C-1.4(d)).
NOTE – An EDD may be prepared by a LSRP or a qualified data preparer on behalf of the responsible party, but the obligation of submitting an accurate EDD lies with the person responsible for conducting the remediation.
How Do I Submit Data?
The analysis of sample data must be completed by a certified lab. However, if your lab is not satisfying all of the EDI criteria or you have old non-compliant data or hard copy data or you're preparing sample data for submittal to a lab etc, SRP has supplied the required format below. There are three options that can be used to create your EDD. Data must be formatted correctly and meet the requirements specified in the SRP-Electronic Data Interchange Manual. An EDD may be prepared by a LSRP or a qualified data preparer on behalf of the responsible party, but the obligation of submitting an accurate EDD lies with the person responsible for conducting the remediation. If the data and/or format submitted do not meet the specified requirements, the submittal will be returned to the LSRP.
The three options that can be used to create your EDD are shown below. It is extremely important to follow the required format for all your data submittals.
- The SRP Template Format
A LSRP or data preparer having access to a computer but limited means of computer support, may find it easier to use the SRP Template Format to meet the data submittal requirements. The SRP Template Format is a basic, stand-alone spreadsheet which outputs to a text, tab-delimited format. All of the required fields are identified in the spreadsheet by column headers. This option is most suitable where the number of samples and the number of analytes for each sample are relatively small. See Appendix 1.
- The Spreadsheet Format
A LSRP or data preparer having access to and familiarity with spreadsheet software can create files with spreadsheets. Each table must be a separate spreadsheet and exported to a "text, tab delimited” (i.e., ASCII, tab-delimited) format.
- The Database Format
A LSRP or data preparer having access to and familiarity with database software can create files with a database. The database must be exported to a "text, tab delimited” (i.e., ASCII, tab-delimited) format.
Regardless of which option is chosen it is necessary to follow the requirements stated in the guidance documents.
When the data tables are complete the LSRP should review each submittal using the the latest version of the Electronic Data Submittal Application (EDSA7). EDSA7 is a data quality checker application that will greatly increase the probability of a successful submittal. SRP cannot guarantee success because the internal version of EDSA7 checks the validity of identifiers (i.e. Preferred ID) against databases that are only accessible within DEP. However, all other aspects of the internal and public checker are the same. In other words, if all your identifiers are correct and your submittal passes EDSA7, and you included the correct identifiers, it will pass the internal version of EDSA7 as well.
After your submittal has passed EDSA7, the LSRP may submit the data as described in the SRP-Electronic Data Interchange Manual.
How will data be used?
The data submitted may be used by SRP inspection/review staff. SRP also uses EDD data in the Remedial Priority System (RPS). For example, EDD data has been collected for approximately 9,000 SRP cases and RPS scores were calculated for each case. SRP studied the EDD data, in conjunction with a LSRP stakeholder group, and developed statistical information used in the RPS score. EDD data and other data, such as the DEP's Geographic Information System and contaminant pathway information, are used to characterize the condition of the case.
In addition, other DEP programs have used the EDD data. For example, the well permitting program uses the EDD data and the DEP’s Geographic Information System to ensure that wells are not being drilled in or near contaminated ground water.
Departments outside of the DEP, such as the Department of Health and others, also use SRP data. The Department of Health has worked with SRP to create a repository of EDD data which is currently being used to study the potential health effects of various contaminants. This repository will form the basis for a state-wide enterprise system that will enable queries of the data.
It is important that all the EDD data be of good quality to make the most effective use of the data. Consequently, SRP will be enforcing more stringent data quality requirements with the release of the new SRP-Electronic Data Interchange Manual and the new data quality checker, EDSA7. Timely data submittals, location information, contaminant information and all other data fields will be reviewed by EDSA7 and SRP staff. If EDDs are not accurate and complete they will be returned to the LSRP.
Who will benefit?
Everyone benefits from the collection of sampling data. Increased understanding of environmental conditions helps SRP protect the health and safety of New Jersey residents. Electronic data is also the foundation for comprehensive decision making when remediating contaminated sites in New Jersey.
In addition , accurate and complete data provides an increased ability to evaluate environmental conditions at individual sites, as well as across the state. Improved data management creates efficiency and ultimately saves tax-payer dollars. A more accurate understanding of environmental conditions protects the health and safety of all New Jersey residents.